Compliance Guidance for Sharing Collection Sites and Buying and Selling Performance Credits 

RPRA is developing compliance guidance for producers and producer responsibility organizations (PROs) to clarify regulatory requirements related to:   

  • Sharing public collection sites to meet accessibility requirements
  • Buying and selling performance credits to meet collection or management requirements 

This guidance is being developed to address compliance challenges identified by registrants.  

The compliance guidance will apply to producers and PROs operating under the following regulations:  

The guidance will result in changes to compliance bulletins and registry procedures related to collection systems and performance credits for the above regulations. 

Based on the differences between the above regulations and the Blue Box Regulation, the guidance will not apply to the Blue Box Regulation.   

RPRA is working with expert consultants to develop this compliance guidance. During the development process, RPRA and the consultants will consult with stakeholders, including direct involvement with those impacted by the new guidance such as PROs.

Consultation process and providing feedback

Phase one (January to April 2024)

In this initial phase, we are seeking feedback from registrants about sharing public collection sites and buying and selling performance credits. This includes direct engagement with PROs as a key group involved in these activities.   

We are looking for responses to the following questions to help us better understand current issues and potential opportunities for resolution: 

  • What, if any, are the current issues associated with sharing sites?  
  • If not, why do you think this is the case? Do you foresee any future issues, if conditions change (e.g., entrance of a new PRO)? 
  • If relevant, do those issues vary by material?  
  • If so, how? 
  • What solutions would address the identified issue? 
  • Are there any concerns you have or advice you would provide to RPRA?  
  • What, if any, are the current issues associated with buying or selling performance credits?  
  • If not, why do you think this is the case? Do you foresee any future issues, if conditions change (e.g., entrance of a new PRO)? 
  • If relevant, do those issues vary by material?  
  • If so, how? 
  • What solutions would address the identified issue? 
  • Are there any concerns you have or advice you would provide to RPRA? 
  • Are there entities RPRA should speak to as part of this process? 

Provide your responses to the above questions and any additional feedback via registry@rpra.ca before the completion of Phase One at the end of April. 

Phase two (May to June 2024)

In the second phase, we will focus on reviewing, addressing and considering the feedback received during phase one to finalize the guidance.  

RPRA aims to publish the compliance guidance by summer 2024. RPRA will share the final guidance, consultation outcomes, and any additional information with impacted registrants at that time.